EPA Pesticide
Program Evaluated, Performance Questioned(Beyond Pesticides, August 4, 2006) The Environmental
Protection Agency’s (EPA) Office of Inspector General (IG) has
issued an evaluation report of the Office of Pesticide Programs (OPP),
entitled Measuring
the Impact of the Food Quality Protection Act: Challenges and Opportunities,
in time for EPA’s August 3, 2006 final tolerance approval deadline
for 231 food use pesticides. The study, which comes on the heels of
a May
24, 2006 letter by EPA scientists alleging the agency is too heavily
influenced by politics and uses bad science in its policy making decisions,
can be viewed as a response to those claims, though it does not directly
address them, and an attempt to validate OPP’s regulatory evaluation
methods.

The study was initiated
to determine OPP’s ability to measure its performance in meeting
the mandates of the Food Quality Protection Act (FQPA); to
determine the strengths and weaknesses of OPP’s current measuring
system; to determine how OPP can “use existing data to measure”;
and what impact FQPA had on mitigating dietary pesticide exposure risk
on children’s health.

Beyond Pesticides
criticizes the report conclusions for assuming that the risk assessments
used by EPA are flawless, at the same time that the agency does not
fully consider the availability of least toxic approaches to pest management.
The report identifies the dilemma faced by OPP, a program with a self-described
mission to serve as a "gateway" for harmful pesticides to
enter the market, while being ill-equipped to track pesticide poisoning
and contamination incidents that may occur as a result of pesticide
use.

Buried in the IG’s
report is a finding that OPP, in order to measure its performance on
regulatory outcomes, can rely on “existing data” that do
not include poisoning incident reports. In fact, none of the data cited
in the report track acute pesticide incident reports. Pesticide incident
report data cannot be used because EPA discontinued its pesticide incident
monitoring system (PIMS) in 1981, leaving no federal system in place
to track pesticide poisoning incidents. Adding to the question of the
reliability of data used for regulatory and policy making decisions
that do not assess incident reports, is the fact that risk assessment,
which does not account for biological variations in the human population
with respect to determining harmful levels of exposure, is heavily relied
upon and is seen as a fool proof and bullet proof evaluation method.
The report fails to recognize the deficiencies in risk assessment that
have been found and documented in numerous studies and reports. The
report apparently accepts risk assessment as a hundred percent credible
without addressing underlying problems of uncertainty, data gaps, and
political influence that are associated with it. EPA’s commitment
to its overall goals of protecting human health and the environment
from pesticide risk is called into question by the failure to recognize
these deficiencies.

Risk assessment
calculations under the federal pesticide registration and tolerance
laws evaluate harm based on false realities about daily toxic exposure
and individual sensitivities. Risk management decisions under these
laws assume the benefits of toxic pesticide products to society or to
various sectors of users, then make a determination that the risks are
“reasonable.” Even under FQPA, which has been touted for
its health-based standard, there is an inherent assumption that if a
pesticide meets a highly questionable “acceptable” risk
threshold, it has value or benefit. This is the practice even though
there are typically less or non-toxic methods or products available.
Absent altogether is any analysis of whether the so-called “pest”
(insect or plant) has been accurately defined. EPA does not regularly
consider non-chemical alternatives (such as organic agricultural methods),
nor does it evaluate the need for or the benefit provided to society
(do we need to use toxic chemicals to kill clover in our yards?).

The report also
indicated that OPP successfully accomplished the reduction of detections
on a core set of 19 foods eaten by children relative to detection levels
for those foods reported in 1994-1996, as well as an apparent increase
in the percentage of acre treatments with "reduced risk" pesticides.

However, such conclusions
do not necessarily reflect increased vigilance on OPP’s part.
For example, the IG found that “risks associated with 16 foods
commonly eaten by children declined by almost 50 percent,” but
does not discuss which pesticides were responsible for the reduction.
The reduction could have come as the result of reduced usage of just
one pesticide, rather than several, or as a result of changes in practices
that are less reliant or not dependent on toxic chemicals. But there
is no way to determine this, nor precisely what was responsible for
the reduction. As a further example, the report discusses methyl parathion,
which has had some of its uses cancelled. These cancelled uses represented
a 90% reduction in the dietary risk to children, dramatically reducing
the estimated dietary risk and thus making the risk “acceptable
for children and all others in the U.S. population.” And in a
discussion of how EPA regulatory actions decrease dietary pesticide
exposure risks, the report indicated that just two pesticides, parathions
and chorpyrifos, were responsible for a 98% reduction in dietary pesticide
exposure risks.

The report found
that EPA has “made progress” in implementing the requirements
of the FQPA, but that OPP has primarily measured its success and the
impact of FQPA by adherence to its registration schedule rather than
by reductions in risk to children’s health. It went on to say
that the “measures used by OPP generally indicate actions taken,
instead of environmental or human health outcomes achieved.” Whether
this is because OPP is less focused and interested in keeping track
of human health outcomes is unclear, as is the degree to which it has
been engaged in achieving such outcomes.

What is clear is
OPP’s commitment to facilitate, and certainly not discourage,
pesticide usage and its seeming lack of a desire to consider least toxic
alternatives. According to the report, “OPP’s mission is
not one of zero risk or zero exposure…OPP must balance its dual
mission of providing a gateway to the marketplace for pesticide products
with the protection of the public from harmful pesticide exposures.”
The degree to which OPP focuses on the former to the detriment of the
latter is the substantive question the report really ought to have considered.